Cypress Semiconductor Corporation v. Deutsche Bank Securities, Inc. et al

Filing 25

ORDER Granting 24 Stipulation Extending Time for Defendants to Respond to Complaint. Signed by Judge Claudia Wilken on 10/25/2011. (ndr, COURT STAFF) (Filed on 10/25/2011)

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William J. Goines (SBN 61290)
GREENBERG TRAURIG, LLP
1900 University Avenue, 5th Floor
East Palo Alto, CA 94303
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Defendants
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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND DIVISION

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CYPRESS SEMICONDUCTOR CORPORATION,
a Delaware Corporation,
Plaintiff,

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Case Number CV-11-617-CW
STIPULATION AND ORDER
EXTENDING TIME FOR
DEFENDANTS TO RESPOND TO
COMPLAINT

v.
DEUTSCHE BANK SECURITIES INC., a
Delaware Corporation, DEUTSCHE BANK ALEX.
BROWN, a Division of Deutsche Bank Securities
Inc., and DEUTSCHE BANK AG,

Honorable Claudia Wilken

Defendants.

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Plaintiff and Defendants, by and through their respective undersigned counsel, stipulate and
agree as follows:

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WHEREAS, on June 2, 2011, the Court So Ordered the parties’ initial stipulation

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extending the time for Defendants to respond to the Complaint in this action to July 11, 2011; and

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WHEREAS, on July 8, 2011, the Court So Ordered the parties’ second stipulation

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extending the time for Defendants to respond to the Complaint in this action through and including
August 24, 2011; and

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WHEREAS, on September 1, 2011, the Court So Ordered the parties’ third stipulation
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extending the time for Defendants to respond to the Complaint in this action through and including
September 23, 2011; and
STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS
TO RESPOND TO COMPLAINT - CV-11-617-CW

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WHEREAS, on September 29, 2011, the Court So Ordered the parties’ fourth stipulation

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extending the time for Defendants to respond to the Complaint in this action through and including

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October 24, 2011; and

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WHEREAS the parties have made substantial progress towards a final resolution of this

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dispute, and believe that an additional thirty (30) days would permit them to finally resolve this
dispute; and
WHEREAS, accordingly, Defendants have met and conferred with Plaintiff and requested
an additional 30-day extension of the time for all Defendants to move against, answer or respond
to the Complaint (through and including November 23, 2011); and
WHEREAS, Plaintiff has consented to Defendants’ request;

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IT IS HEREBY STIPULATED, by and between Plaintiff and Defendants, through their
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respective counsel, and subject to Court approval, that the time for all Defendants to move against,

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answer or respond to the Complaint shall be extended from October 24, 2011 through and

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including November 23, 2011.

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In accordance with General Order 45 of the United States District Court for the Northern

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District of California, I attest that concurrence in the filing of this document has been obtained

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from the undersigned counsel.

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DATED: October 24, 2011

Respectfully submitted,

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By

/s/ Philip J. Wang
Philip J. Wang (SBN 218349)
Justin S. Chang (SBN 205925)
WANG & CHANG, A PROFESSIONAL
LAW CORPORATION
One Maritime Plaza, Suite 825
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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Attorneys for Plaintiff
STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS
TO RESPOND TO COMPLAINT - CV-11-617-CW

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By

/s/ William J. Goines
William J. Goines (SBN 61290)
GREENBERG TRAURIG, LLP
1900 University Avenue, 5th Floor
East Palo Alto, CA 94303
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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- and Stephen L. Saxl (Pro Hac Vice Motion
To Be Filed)
Toby S. Soli (Pro Hac Vice Motion
To Be Filed)
GREENBERG TRAURIG, LLP
200 Park Avenue
New York, New York 10166
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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Attorneys for Defendants

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ATTESTATION CLAUSE

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I, William J. Goines, am the ECF User whose ID and password are being used to file this
STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS TO
RESPOND TO COMPLAINT. In compliance with General Order 45, X.B., I hereby attest that
Philip J. Wang has concurred in this filing.

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Date: October 24, 2011

GREENBERG TRAURIG, LLP

By: /s/ William J. Goines

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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS
TO RESPOND TO COMPLAINT - CV-11-617-CW

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

DATED:

October 25
________________, 2011
The Honorable Claudia Wilken
United States District Judge

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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS
TO RESPOND TO COMPLAINT - CV-11-617-CW

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